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CWT FARMS, INC. v. C.I.R.

No. 84-8012.

755 F.2d 790 (1985)

CWT FARMS, INC. and CWT International, Inc., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

March 19, 1985.

Attorney(s) appearing for the Case

W. Woodrow Stewart, Steven A. Cornelison, Gainesville, Ga., for petitioners-appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, David English Carmack, Tax Division, U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before HENDERSON and HATCHETT, Circuit Judges, and NICHOLS, Senior Circuit Judge.

HATCHETT, Circuit Judge:

In this case, we affirm the United States Tax Court's, 79 T.C. 86, determination that CWT International, Inc. did not qualify for tax treatment as a domestic international sales corporation.

CWT Farms, Inc. (Farms) and CWT International (International) are Georgia corporations with their principal places of business in Gainesville, Georgia. Twin Oaks Hatchery...

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